Income Tax Keyed to Lind
Commissioner v. Crichton
Respondent and her three children owned a tract of land and an improved city lot. The children transferred their interests in the city lot to Respondent, and she transferred oil, gas, and mineral rights to the children. The interest to Respondent had a value of $15,357.77, and the interest to the children had a cost basis of zero. Respondent treated the exchange as a like kind property exchange and nontaxable. The Commissioner of Internal Revenue determined the exchange resulted in a capital gain of the full amount.
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